Tax advisors, accountants, banks, lawyers, and other intermediaries who design and promote potentially aggressive cross-border tax planning schemes and, in some cases, the clients that receive such advice, would be required to meet new reporting. . .
Irish chartered accountant JP Canavan discusses Ireland’s decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .
Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
India transfer pricing specialist Ajit Jain discusses the government’s June 7 decision to add a new transfer pricing safe harbor for low-value adding intragroup services and reduce existing safe harbor margins for knowledge process outsourcing services, contract research and development services, and other services.. . . .
Eight countries are working on a new program to jointly review large multinationals’ tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO’s risk assessment framework for cross-border related party financing . . .
Davide Anghileri of the University of Lausanne discusses an ECOFIN deal, reached May 23, for a directive that will create a new system for resolving double taxation disputes between the EU States; he also provides an update of EU discussions on adopting a common corporate tax base (CCTB) . . .
The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .